The Washington, D.C. Department of Insurance, Securities, and Banking (DISB) has published a Bulletin reminding those who service student education loans in the District of Columbia of their obligation to file an annual report.

Section 3014 of the DISB’s regulations, finalized August 10, 2018, requires that a licensee submit an annual report, on or before January 30 and in a form prescribed by the Commissioner, describing the number of student loans sold, assigned, or transferred during the preceding calendar year and any other information required by the Commissioner. The Bulletin does not state that the annual report form has been finalized, although it is anticipated that the DISB will release the report in the next month. The Bulletin also does not state whether the DISB will require an annual report for calendar year 2018 and, if so, when licensees must file such a report. Failure to file a timely report is subject to a late penalty of up to fifty dollars per day.

Because the federal district court for the District of Columbia found provisions of the District’s student loan servicing law to be preempted by the Higher Education Act in Student Loan Servicing Alliance v. District of Columbia, et al., the Bulletin clarifies that “a licensee is only required to provide information on the licensee’s non-federally owned loans.”